LAUREL, Md. — EPA and OSHA go about enforcing their regulations differently. The Environmental Protection Agency tells dry cleaners specifically what to do and applies the same standard across the industry. The Occupational Safety and Health Administration issues a framework and expects operators to work out the application themselves. For small businesses, the second approach is usually harder.

Jon Meijer, director of membership for the Drycleaning & Laundry Institute (DLI), covered the key OSHA requirements during a recent DLI webinar, “Regulatory Update for Garment Care Professionals.”

In Part 1, we explored the coming perc ban and what it means to dry cleaners. In Part 2, we examined the PFAS puzzle for dry cleaners and the state of alternative solvents. Today, we’ll conclude by considering how best to deal with OSHA expectations.

Meijer’s advice: Know the three things an inspector will look for, and don’t create problems that don’t need to exist.

The most common source of citations in the drycleaning industry is the Hazard Communication Standard (HCS), Meijer says, also called the “Right to Know.” It has three components: a written program, a file of Safety Data Sheets accessible to employees, and documented employee training.

Meijer has found that the written program doesn’t have to be complicated. He’s been surprised by how well AI tools handle it.

“With the advent of ChatGPT or things of that nature, you can actually have Chat build you a training program,” he says. “It’s not that hard.”

Safety Data Sheets should be on file for every chemical used in the plant — spotting solutions, solvents, and everyday products like bleach if used in higher volumes than a typical consumer would. Distributors are required to provide them, and free versions are available online for most products. Meijer recommends keeping one copy for the office and one on the floor, accessible to employees.

Training must cover everyone in the plant, Meijer says, and that means everyone. If you have employees whose primary language is Spanish, training must be conducted in Spanish.

When the HCS first took effect, Meijer says he put up signs throughout DLI’s facility, including one posted directly in front of a textile chemist conducting an ammonia bath: Employees must wear goggles when working with ammonia.

He admits now that he overdid it.

“The OSHA inspector came in, looked at the sign, looked down at the textile chemist, looked at the sign again and created a violation that never, never needed to be,” he says.

As soon as the inspector left, the sign came down.

“I ripped down every sign except the exact ones that I needed,” Meijer says.

Meijer’s practical takeaway: Put up labels and signs where they serve a genuine safety purpose. Mark the eyewash station. Label containers on spotting boards. Train employees on what the labels mean and where emergency equipment is located. Beyond that, however, less is more.

The second area inspectors may look at is lockout/tagout — the requirement that any machinery being serviced must be physically locked or tagged out of operation before anyone works on it. The rule exists to prevent equipment from being activated while a technician is behind or inside the unit.

Meijer has a personal reason for taking it seriously.

“When I was young and stupid, I was in the back doing an air reading from a steam vent, and somebody turned it on,” he says. ”I ended up having to go to the hospital. My face basically peeled off over a couple of days as the steam got to me, because I didn’t tell anybody I was back there.”

This is an example of the exact scenario the rule is designed to prevent. DLI has a sample lockout/tagout program available, Meijer says, and anyone who needs one can contact him directly or find it through the DLI website.

The third area — and the one most likely to affect the broadest range of dry cleaners — is heat stress. A final federal rule hasn’t been published, but the issue isn’t going away, Meijer says, and drycleaning plants and launderers were specifically named in OSHA’s proposed rulemaking.

With the federal rule stalled, a number of states have moved ahead with their own standards, creating a patchwork that’s difficult for any business to follow consistently. Meijer says that DLI has pushed OSHA for a workable, uniform regulation that accounts for the realities of how plants actually operate.

“We’ve asked OSHA to come up with a regulatory scheme that is fair and sets a standard that keeps dry cleaners and launderers in business,” Meijer says.

What that standard might look like in practice includes cooling options, water breaks and designated rest areas. Most plants already manage peak processing in the morning to reduce afternoon heat exposure. Whatever solutions a plant uses, Meijer says, they need to be documented and consistent.

For Part 1 of this series, click HERE. For Part 2, click HERE.